Transfer pricing rules at panama's tax administration he is also a 2016 phd in law candidate at dauphine university jose's phd thesis emphasizes transfer pricing approaches concerning the oil industry as an advisor, he dictates the module “arm's length principle and transfer pricing methods” for ciat and coordinates. Doctor of philosophy department of economics university of toronto 2010 this thesis examines the income-shifting behaviour of multinational corporations when professor mintz had been on my phd committee till he left the university of toronto to 344 non-arm's length transactions and transfer pricing rules. Item type: thesis or dissertation (phd) subjects: h social sciences hd industries land use labor library of congress subject headings (lcsh):, international business enterprises -- egypt, transfer pricing -- egypt, profit- sharing -- egypt, egypt -- economic conditions official date: february 1992 dates:. He also said the un model tax treaty's commentary to article 9 will be updated in 2017 to make it consistent with oecd transfer pricing work on intangibles the un and i am a phd student writing a thesis on transfer pricing issues and have really learnt a lot from your discussions keep up the great work. Abstract this article compares the profit split method (“psm”), one of the transfer pricing methods for the application of the arm's length principle, with formulary apportionment (“fa”) which is discussed as an alternative to the arm's length principle as such in the course of this article, we analyze and.
Senior lawyer, phd oddleif is a senior lawyer in the firm's tax department he holds a doctoral degree in international tax law from the university of bergen on the thesis arm's length transfer pricing related to intangible assets is a priority area for tax authorities worldwide, including the norwegian tax authorities oddleif. Transfer pricing cases, and (b) the mechanisms used by indonesian tax auditors to ensure appropriate tax our knowledge prior research on tax audit adjustments for multinational transfer pricing issues has not included perspective, unpublished phd thesis, university of new south wales, australia navarro, c l and. Phd, elísio fernando moreira brandão september 2016 besides my advisor, i would like to thank the thesis committee: professor elísio brandão professor antónio cerqueira and of intra-group financing using derivatives instruments on transfer pricing aggressiveness based on a selective sample of. Tinbergen magazine 13, spring 2006 letters from alumni life after the phd thesis defense transfer pricing is a multidisciplinary subject occupying the time and talents of (tax) lawyers, accountants and economists you basically provide advice to multinational enterprises in determining arm's length transfer prices from a tax.
Université du québec à montréal transfer pricing: why the tax havens will endure thesis presented as partial requirement of the masters of international law by daria kapnik june 2013. This thesis concerns the issue of how mne affects their taxable profit through transfer pricing when companies transfer assets between subsidiaries in different states they need to price the assets so the taxable profit that arises reflects the value of the subsidiary the pricing is calculated to comply with 'arm's length price',.
Multinational transfer pricing – a new documentation paradigm a dissertation submitted for the degree of master in tax law, under the orientation of professor tomás cantista tavares, phd efigénia marabuto tavares student no 340110107 porto, may 2016. Rogers, helen, phd (2009) uncertainty in transfer pricing tax rules : the role of apas phd thesis, university of warwick full text not available from this repository official url: http://webcatwarwickacuk/record=b2491816~s15 abstract transfer pricing is an important issue for transnational enterprises ( tnes) seeking to. These activities involve all the transfer pricing community at the institute for austrian and international tax law (including professors, research associates, visiting researchers, llm students) and outside the institute (including international organizations, governments and tax administrations, the business community, and. Business administration thesis synopsis gabriella erdős cross-border mergers the conformity of the hungarian corporation tax rules with that of the european union phd dissertation supervisors: transfer pricing and state aid aspects are only investigated to the extent of their immediate corporation tax effect.
Second, i intended to write a phd thesis on international taxation to spend more time on this research area to enforce tax obligations on households' worldwide capital income in this phd thesis otherwise, there 1the manipulation of transfer prices as well as proﬁt- and debt-shifting across countries are popular. An empirical investigation of transfer pricing regulations for nigeria with a particular emphasis on the petroleum sector kalli zannah a thesis submitted in partial fulfilment of the requirements of robert gordon university for the degree of doctor of philosophy aberdeen business school the robert gordon university.